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TRADESMITH PRIVACY POLICY

Updated: February 16, 2023

This Privacy Policy applies to information TradeSmith, LLC (“TradeSmith,” “we,”
“our,” and/or “us”) collects from all sources, including in connection with our
website located at https://tradesmith.com/ and affiliated websites
(collectively, the "Sites") any mobile or other website operated by us, the
software applications made available by us for use on or through computers and
mobile devices (the "Apps"), and our publications, newsletters, memberships,
portfolio solutions, webinars, conference calls, e-letters, blogs, books,
electronic communications, widgets, conferences and events (collectively with
Sites and Apps, the "Services"). By providing personal information to us or by
using our Services, you agree to this Privacy Policy. Please read the Privacy
Policy carefully before using or submitting information via our Services.

I. Information Collection

When you use our Services, we collect personal information that you voluntarily
provide to us, including your name, postal address (including billing and
shipping address, telephone number, email address, and any other information
that you choose to provide to us). Examples of when we collect this information,
include, but are not limited to, when you join our email list, sign up for text
alerts, create an account, sign up for webinars, contact us, or interact with us
for any other purpose. We may also collect your mailing and billing information
when you place an order with us. 

We may also collect technical information relating to your interactions with us
and our Services, such as IP address, cookie identifiers, mobile device
identifiers, browser and device type, time and date of visit, and pages visited
and other activities on the Services. We may use cookies or similar technologies
to collect such information for advertising and other purposes. Please see
Section IV. Digital Advertising & Analytics of this Privacy Policy to learn more
about the use of this information and the choices available to you. 

When you use the Apps that we offer, we may request permission to access certain
functions such as your camera, photos or location information. We may use this
information to provide our products and services to you. If you do not want us
to access this information, please use the settings available on your mobile
device to deny these permissions. Please note that if you prevent us from
accessing these functions, certain features of the App may not work.

II. Information Use

We may use the information we collect for any lawful purpose, including the
following:

 * To maintain, operate, customize, and improve our Services, including for
   analytics purposes;
 * To provide and improve our Services, including Services we may develop in the
   future; 
 * To respond to your inquiries or contact you as you request;
 * To send updates, promotions, and marketing materials that may be of interest
   to you; 
 * To comply with the law and maintain the security of our Services; and/or
 * For any other purpose for which you have given your consent, or for any other
   purpose disclosed at the time of collection.

III. Information Sharing

We may share the information we collect with other parties, including the
following:

 * With third-party vendors that perform services on our behalf, such as hosting
   providers, e-mail service providers, and payment processors;
 * With any affiliates or joint venture parties we may have business
   relationships with currently or in the future;
 * As part of a corporate sale, merger, or acquisition, or other transfer of all
   or part of our assets, including as part of a bankruptcy proceeding; 
 * Pursuant to a subpoena, court order, governmental inquiry, or other legal
   process or as otherwise required by law, or to protect our rights or the
   rights of third parties; or
 * With your consent or as otherwise disclosed at the time of data collection or
   sharing.

We may share information that has been de-identified (“anonymized”), without
limitation.


 

IV. Digital Advertising & Analytics

We may partner with ad networks and other ad serving providers (“Advertising
Providers”) who serve ads on behalf of us and others on non-affiliated sites.
Some of those ads may be personalized, meaning they are intended to be relevant
to you based on information Advertising Providers collect about your visits to
our Services and other non-affiliated sites or applications over time, including
information about the possible relationships among different browsers and
devices. This type of advertising is known as interest-based advertising.

Tradesmith adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory
Principles in connection with this interest-based advertising activity and to
the European Digital Advertising Alliance (“EDAA”) Principles in the European
Union (“EU”) in connection with this interest-based advertising activity. You
may visit www.aboutads.info/choices or http://youronlinechoices.eu (if you are
located in the EU) to learn more about this type of advertising and how to
opt-out of this advertising on your browser by companies participating in this
industry choice tool. If you wish to opt-out of interest-based advertising in
mobile apps on your device by companies that participate in the Digital
Advertising Alliance’s (“DAA”) AppChoices app, you may download the app onto
your device and exercise your choice. 

AppChoices is available at the links below:

DAA AppChoices iOS

DAA AppChoices Android

Note that electing to opt-out will not stop advertising from appearing in your
browser or applications. It may make the ads you see less relevant to your
interests. If you use a different browser or device, you should renew your
opt-out choice on each browser or device. 

You may also be able to use browser settings to block cookies by activating a
setting on your browser that allows you to refuse the setting of all or some
cookies. However, if you use your browser settings to block some or all cookies,
our Services may not function as intended. We may also work with other third
parties that collect data about your use of the Services over time for
non-advertising purposes. We use Google Analytics and other third-party services
to improve the performance of our Services and for analytics and marketing
purposes. For more information about how Google Analytics collects and uses data
when you use our Services
visit https://www.google.com/policies/privacy/partners.

To opt-out of Google Analytics visit https://tools.google.com/dlpage/gaoptout/. 

Additionally, your browser may offer tools to limit the use of cookies or to
delete cookies; however, if you use these tools, our Sites may not function as
intended.



V. Third-Party Links and Tools

We may provide links on our Services to websites or applications maintained by
third parties, including links to social media sites. These websites and
applications are independent from TradeSmith and have their own privacy
policies. TradeSmith does not control the privacy practices of those websites or
applications, and they are not covered by this Privacy Policy. You should review
the privacy policies of other websites or applications that you use to learn
about their data practices.

Our Services may also include integrated social media tools or “plug-ins,” such
as social networking tools offered by third parties. If you use these tools to
share personal information or you otherwise interact with these features on our
Services, those third parties may collect information about you and may use and
share such information in accordance with your account settings, including by
sharing such information with the general public. Your interactions with these
third parties and the use of their features are governed by their privacy
notices. We encourage you to carefully read the privacy notices of any accounts
you create and use.

VI. Cookies

Some of our Services use cookies and similar technologies. A cookie is a small
file of letters and numbers that we store on your browser or the hard drive of
your computer if you agree. You can find more information about the individual
cookies and similar technologies used in our Services and for the purposes for
which they are used in our Cookie Policy.

VII. Your Choices

If you decide that you no longer wish to receive marketing emails from us, you
can unsubscribe from our email distribution list by clicking the “unsubscribe”
link located at the bottom of each promotional email or by using the contact
information listed below. Please allow us up to 10 days to complete your
unsubscribe request. After you opt-out, we may continue to send you emails
related to our relationship or transactions with you, such as responding to your
questions. 

With your consent, we may send marketing-related and/or transactional SMS text
messages to your mobile device. You can opt-out of these messages at any time by
replying with the word “STOP” to each SMS shortcode to which you are subscribed.
To the extent you receive notifications from any of our Services, you may
opt-out of receiving push notifications on your mobile device through your
device and account settings. 

Personal information collected through the short code program won’t be sold or
rented to, or shared with third parties for their own marketing purposes.

For choices with respect to third-party interest-based advertising activities,
please see Section IV. Digital Advertising & Analytics above.


 

VIII. California Privacy Rights

This section contains disclosures required by the California Consumer Privacy
Act (“CCPA”) and applies only to “personal information” that is subject to the
CCPA.  

A. Personal Information We Collect. In the preceding 12 months, we collected the
following categories of personal information about California consumers.  

Categories of Personal Information 
Disclosed for business purposes to the following categories of third parties:
Sold for business purposes to the following categories of third parties:
Personal and online identifiers (such as first and last name, email address, or
unique online identifiers)

 * Service providers;
 * Related affiliates; 
 * Advertising networks;
 * Data analytics providers;
 * Operating systems and platforms; and
 * Social networks.


 * Advertising networks;
 * Marketing data companies;
 * Data analytics providers;
 * Operating systems and platforms;
 * Financial services companies;
 * Related affiliates. 


Categories of information described in Section 1798.80(e) of the California
Civil Code (such as physical characteristics or description, insurance policy
number, bank account number, credit card number, debit card number, or any other
financial information, medical information, or health insurance information)
Characteristics of protected classifications under California or federal law
(such as race or gender)
Commercial or transactions information (such as records of personal property or
products or services purchased, obtained or considered)
Internet or other electronic network activity information (such as browsing
history, search history, interactions with a website, email, application, or
advertisement)
Biometric information (such as call recordings)
Geolocation information
Professional or employment-related information
Education information
Inferences drawn from the above information about your predicted characteristics
and preferences





(I) Categories of Sources. We may collect personal information from the
following categories of sources: 

 * Consumers
 * Data analytics providers
 * Third-party data providers
 * Operating systems and platforms, and
 * Related affiliates

(ii) Why We Collect, Use, and Share California Personal Information. We may use
and disclose the personal information we collect for our commercial and business
purposes, as further described in this Privacy Policy.  These commercial and
business purposes include, without limitation:

 * Our commercial purposes, including marketing, advertising, and enabling
   commercial transactions.
 * Our business purposes as identified in the CCPA, which include, but are not
   limited to:
   * Auditing related to our interactions with you;
   * Legal compliance;
   * Detecting and protecting against security incidents, fraud, and illegal
     activity;
   * Debugging;
   * Performing services (for us or our service provider) such as account
     servicing, processing orders and payments, and analytics;
   * Internal research for technological improvement;
   * Internal operations;
   * Activities to maintain and improve our services.

B. Your Rights Regarding California Personal Information. California residents
have certain rights with respect to the personal information collected by
businesses.  If you are a California resident, you may exercise the following
rights regarding your personal information, subject to certain exceptions and
limitations:

 * The right to know the categories and specific pieces of personal information
   we collect, use, disclose, and sell about you; the categories of sources from
   which we collected personal information about you; our purposes for
   collecting or selling personal information about you; the categories of
   personal information about you that we have either sold or disclosed for a
   business purpose; and the categories of third parties with which we have
   shared personal information.
 * The right to request that we delete the personal information we have
   collected from you, subject to certain exceptions.
 * The right to opt-out of our sale(s) of your personal information. Please note
   that if you opt-out of certain types of sales, we will be unable to provide
   you with the services that rely on such sales.
 * The right not to receive discriminatory treatment for the exercise of the
   privacy rights conferred by the CCPA.

To exercise any of the above rights, please submit your request with the
required verifying information HERE, or see Section XII. Contact Us below
regarding how to contact us by phone.

C. Verification Process and Required Information. Note that we may need to
request additional information from you to verify your identity or understand
the scope of your request, although you will not be required to create an
account with us to submit a request or have it fulfilled.  We will require you
to provide, at a minimum name, email address, and country.

D. Authorized Agent. You may designate an authorized agent to make a CCPA
request on your behalf. If you use an authorized agent to submit such a request,
we will require written proof that the authorized agent has been authorized to
act on your behalf or a copy of the power-of-attorney document granting that
right.

E. Minors’ Right to Opt-In. We do not have actual knowledge that we sell the
personal information of minors under 16 years of age.


 

IX. European Privacy Rights

This section applies to individuals that visit or use our Services from the
European Economic Area, United Kingdom, and Switzerland. 

A. Legal Basis for Processing

TradeSmith processes personal information with your consent. For example,
TradeSmith processes personal information to provide goods and services you
request. 

On certain occasions, we process your personal information when it is necessary
for the performance of a contract to which you are a party, such as to provide
products and services to you that you have requested. We may also process your
personal information to respond to your inquiries concerning our products and
services. 

On other occasions, we process your personal information where required by law.
We may also process your personal information if necessary to protect your
interests or the interests of a third party. 

Additionally, we process your personal information when necessary to do so for
our legitimate interests, and these interests are not overridden by your data
protection rights. Where we process your personal information for this purpose,
our legitimate interest is to provide and secure our Services. 

If the processing of personal information is necessary and there is no statutory
basis for such processing, we will ask for your consent to process your personal
information. You have the right to withdraw your consent to processing of
personal information at any time. 

B. Transfers of Personal Information

Please be aware that the personal information we collect may be transferred to
and maintained on servers or databases located outside your state, province,
country, or other jurisdiction, where the privacy laws may not be as protective
as those in your location. If you are located outside of the United States,
please be advised that we process and store personal information in the United
States. 

We will only transfer your personal information if:

 * The country to which the personal information will be transferred has been
   granted a European Commission adequacy decision; or
 * We have put in place appropriate safeguards with respect to the transfer. 

C. Rights Under the GDPR

You have a right to the following:

 * To request access to the personal information we hold about you;
 * To request that we rectify or erase your personal information, subject to
   certain exceptions;
 * To request that we restrict or block the processing of your personal
   information;
 * Under certain circumstances, to receive personal information about you that
   we store and transmit to another without hindrance from us, including
   requesting that we provide your personal information directly to another
   (i.e., a right to data portability); and
 * Where we previously obtained your consent, to withdraw consent to processing
   your personal information. 

To exercise any of the above rights, please submit your request with the
required verifying information HERE. Please see Section XII. Contact Us below
regarding how to contact us by phone. Please be aware that TradeSmith may be
unable to afford these rights to you under certain circumstances, such as if we
are legally prevented from doing so. 

Additionally, you have the right to lodge a complaint against us. To do so,
contact the supervisory authority in your country of residence.



X. Security Measures

TradeSmith has established reasonable precautions to protect collected personal
data from loss, misuse, unauthorized access, disclosure, alteration or
destruction, which include contractual, administrative, physical, and technical
steps. Technical measures include use of firewall protection and encryption
technology where appropriate. Please note that while we have endeavored to
create a secure and reliable site for users, the confidentiality of any
communication or material transmitted to/from TradeSmith cannot be guaranteed.

XI. Changes to Our Privacy Policy

TradeSmith may make changes to this Privacy Policy from time to time. You should
check this page periodically to learn of any updates. If we make changes to this
Privacy Policy, we will post the amended version via our Services and the
effective date will be updated. Your continued use of the Services indicates
that you agree to those updates.

XII. Contact Us

If you have questions, comments, or concerns about this Privacy Policy or
TradeSmith’s practices, 
please contact us at: (866) 385-2076, support@tradesmith.com, or by mail at the
following address:

TradeSmith
P.O. Box 3039
Spring Hill, FL 34611




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